Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 07 3:23 PM-20CV007082
06337 - R3
Kerschner, Matthew
From: Kerschner, Matthew
Sent: Wednesday, January 4, 2023 4:56 PM
To: ‘troy@doucet.law'
Ce: Gordon, Sean A.
Subject: RE: APF CRE | LLC, et al v. Tehrah Hospitality LLC, et al; Case No 20CV007082
Troy:
As previously noted, we followed up with our clients to confirm status of compilation of the relevant materials and data,
as our client contacts were not entirely available over the past two weeks due to the holidays and other travel
commitments. Our conversation with them this week confirmed that they have identified additional relevant materials,
which they are providing to our team this week to review for privilege and other objections, and prepare for labelling
and production. Based on the volume of materials we have received and are receiving, we expect to continue rolling
production of materials on or around Tuesday, January 17, 2023 (i.e., the date that we previously requested for an
extension, after factoring in the federal holiday on Monday, January 16).
We will of course keep you timely apprised of any changes to this estimate, as well any other developments as we
complete our rolling production. As the continued hearing is now in April 2023, we are confident you will have ample
lead time to review our clients’ production to prepare for the hearing and deal with any remaining discovery matters. If
more time ends up being necessary for any valid reason, we will work with you on scheduling in good faith so that you
and your clients are not prejudiced by the timing of our rolling document production and ongoing efforts to comply with
your discovery requests.
Best,
Matt
Matthew J. Kerschner : Managing Associate | Thompson Hine LLP
3900 Key Center, 127 Public Squar leveland, Ohio 44114
O: 216.566.5834 | M: 216.407.5498
F: 216.566.5800 : www.ThormpsenHine.com
Matthew Kerschner @ Thompsentine.com
From: troy@doucet.law
Sent: Wednesday, January 4, 2023 9:54 AM
To: Kerschner, Matthew
Subject: RE: APF CRE I LLC, et al v. Tehrah Hospitality LLC, et al; Case No 20CV007082
Matt,
This is not sufficient. Your client does not get to dictate when it decides to deliver discovery to us. What is the next date
of production you expect?
Sincerely,
Troy Doucet
Via Emily Bonzani, Executive Assistant
Doucet Gerling Co., LPA
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 07 3:23 PM-20CV007082
06337 - R34
655 Metro Place South, Suite 600
Dublin, OH 43017
Direct: (614) 221-9800
Toll Free: (888) 200-9824
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Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 07 3:23 PM-20CV007082 06337 - R3 Kerschner, Matthew From: Kerschner, Matthew Sent: Wednesday, January 4, 2023 4:56 PM To: ‘troy@doucet.law' Ce: Gordon, Sean A. Subject: RE: APF CRE | LLC, et al v. Tehrah Hospitality LLC, et al; Case No 20CV007082 Troy: As previously noted, we followed up with our clients to confirm status of compilation of the relevant materials and data, as our client contacts were not entirely available over the past two weeks due to the holidays and other travel commitments. Our conversation with them this week confirmed that they have identified additional relevant materials, which they are providing to our team this week to review for privilege and other objections, and prepare for labelling and production. Based on the volume of materials we have received and are receiving, we expect to continue rolling production of materials on or around Tuesday, January 17, 2023 (i.e., the date that we previously requested for an extension, after factoring in the federal holiday on Monday, January 16). We will of course keep you timely apprised of any changes to this estimate, as well any other developments as we complete our rolling production. As the continued hearing is now in April 2023, we are confident you will have ample lead time to review our clients’ production to prepare for the hearing and deal with any remaining discovery matters. If more time ends up being necessary for any valid reason, we will work with you on scheduling in good faith so that you and your clients are not prejudiced by the timing of our rolling document production and ongoing efforts to comply with your discovery requests. Best, Matt Matthew J. Kerschner : Managing Associate | Thompson Hine LLP 3900 Key Center, 127 Public Squar leveland, Ohio 44114 O: 216.566.5834 | M: 216.407.5498 F: 216.566.5800 : www.ThormpsenHine.com Matthew Kerschner @ Thompsentine.com From: troy@doucet.law Sent: Wednesday, January 4, 2023 9:54 AM To: Kerschner, Matthew Subject: RE: APF CRE I LLC, et al v. Tehrah Hospitality LLC, et al; Case No 20CV007082 Matt, This is not sufficient. Your client does not get to dictate when it decides to deliver discovery to us. What is the next date of production you expect? Sincerely, Troy Doucet Via Emily Bonzani, Executive Assistant Doucet Gerling Co., LPA Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Apr 07 3:23 PM-20CV007082 06337 - R34 655 Metro Place South, Suite 600 Dublin, OH 43017 Direct: (614) 221-9800 Toll Free: (888) 200-9824 LEADERS IN LOAN LITIGATION Top rated lawyers who serve people and businesses that are facing challenging legal issues. This email is intended only for the use of the party to whom it is addressed, and it may contain information that is privileged, confidential, or protected by law. If you are not the intended recipient you are hereby notified that any dissemination, copying, or distribution of this e-mail or its contents is strictly prohibited. If you have received this message in error, please notify us immediately by replying to this message and deleting it from your computer. Internet communications are not assured to be secure or clear of inaccuracies; information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. Therefore, you should contact us before opening any attachment if you are not expecting an attachment from us. How have you helped those less fortunate today?